State v. Wint
198 A.3d 963
N.J.2018Background
- Laurie Wint was arrested in Camden (NJ) on a murder charge and, after Miranda warnings, invoked his right to counsel; questioning by Camden investigators ceased.
- About three minutes later two Pennsylvania detectives entered and, after Miranda warnings, Wint again requested counsel; they stopped questioning.
- Over the next months the Pennsylvania detectives prompted brief informal comments from Wint (at their initiative) that he would talk when taken to Bucks County; Wint remained in continuous pre-indictment custody in Camden.
- Six months later Wint was transported to Bucks County, read Miranda warnings again, waived rights, and allegedly admitted to a Camden killing; that statement was used at trial.
- Trial court admitted the statement; jury convicted Wint of passion/provocation manslaughter and related offenses. Appellate Division remanded for attenuation and Shatzer break-in-custody analysis. The Supreme Court reversed and ordered a new trial on the homicide count, suppressing the Pennsylvania statement.
Issues
| Issue | Plaintiff's Argument (Wint) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether Pennsylvania detectives violated Edwards by reapproaching Wint minutes after he invoked counsel in Camden | Edwards barred any further police-initiated interrogation after invocation; the detectives violated Edwards | The detectives did not unlawfully reinitiate because Wint’s later remarks showed conditional willingness to talk | Court: Violation occurred; detectives impermissibly reinitiated questioning minutes after invocation |
| Whether Wint’s later comments constituted initiation of communication waiving Edwards protection | Wint did not initiate; his responses were prompted by detectives and insufficient to reopen interrogation | State: Wint’s repeated statements that he would talk in Pennsylvania show he initiated contact | Court: Wint did not initiate; remarks were responses to detective prompts |
| Whether six-month interval in continuous pre-indictment custody constituted a Shatzer "break in custody" that dissipated coercive effects | A pre-indictment detainee’s continued jail custody is not a break in custody; Shatzer’s 14-day rule applies to those released to normal life, not to detainees | State: Shatzer’s break-in-custody concept applies and the six months sufficed; county jail return is analogous to prison population return | Court: No break in custody under Shatzer for pre-indictment detainees here; continuous pretrial detention did not dissipate coercive effects |
| Whether the Edwards presumption is subject to attenuation analysis (Brown factors) | Edwards forbids attenuation inquiry where defendant invoked counsel; suppression is required absent exceptions | State and App. Div.: Remand for attenuation and break-in-custody analyses | Court: No attenuation analysis; Edwards presumption applies and statement suppressed because none of exceptions (counsel present, defendant-initiated, break in custody) applied |
Key Cases Cited
- Edwards v. Arizona, 451 U.S. 477 (Establishes that once counsel is requested police-initiated interrogation must cease)
- Arizona v. Roberson, 486 U.S. 675 (Edwards protection applies across separate agencies and investigations)
- Minnick v. Mississippi, 498 U.S. 146 (Once counsel is requested officials may not reinitiate interrogation even if suspect consulted counsel)
- Maryland v. Shatzer, 559 U.S. 98 (Creates break-in-custody exception to Edwards; 14-day rule for dissipating coercive effects)
- Miranda v. Arizona, 384 U.S. 436 (Requires warnings and cessation of interrogation upon request for counsel)
- McNeil v. Wisconsin, 501 U.S. 171 (Edwards rule is not offense-specific)
- Michigan v. Mosley, 423 U.S. 96 (Attenuation and voluntariness analysis in silence-invocation context)
- Brown v. Illinois, 422 U.S. 590 (Factors for attenuation analysis of taint from prior illegality)